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Canada Organic Office - Operating Manual

Part C - Certification of Organic Product and CB Requirements

Table of Contents

Preamble

These requirements apply to the accredited CB during every initial, surveillance or reassessment audit conducted by the CVB.

C.1 Objective

This section provides information about the certification cycle, including application for certification, evaluation, decision on certification and continuation of the certification under the Canada Organic Regime (COR). It also provides requirements on the CB.

C.2 Procedures for certification under COR

C.2.1 Application for Initial Certification of Agricultural Product

C.2.1.1 The CFIA accredited CB shall ensure that operators seeking certification of their organic product or process shall make an application as defined by the CB.

C.2.1.2 The CB shall require that the applicant provide all the relevant documents and information deemed essential to the assessment as described in Section 14 (2) from the Regulations and Appendix A. These documents shall include as a minimum:

  1. production description: production and/or preparation specifications for products to which the application applies;
  2. maps and plans;
  3. list of inputs (ingredients and agricultural substances);
  4. a copy of organic production and/or preparation plans;
  5. names of Certification Bodies to which prior applications for certification were submitted by the applicant within the previous years, including all details pertaining to processing the application, and the resulting decision.

C.2.1.3 The CB shall send acknowledgement of the application reception to the applicant.

C.2.1.4 The CB shall ensure that the applicant pays the fees for certification according to the CB's contract for services and in accordance with the CB's fee schedule

C.2.2 Preparation for On-Site Inspection

C.2.2.1 The CB shall document its procedure for its evaluation activities. The CB shall evaluate the products of the applicant against the requirements set out in CAN/CGSB 32.310 and CAN/CGSB 32.311.

C.2.2.2 The CB shall not permit the operators to choose or to recommend the VO except in cases of conflict of interest.

C.2.2.3 The CB shall record the VO selected to evaluate the conformance of the operator's product or process.

C.2.2.4 The CB shall ensure that the operator is contacted to arrange the logistics of the on-site inspection.

C.2.3 On-Site Inspections

C.2.3.1 The CB shall perform a visual examination of all components and production units (e.g. fields, crops and plants, livestock, buildings and facilities) the evaluation of a product shall cover all production and processing operations, including packaging and labelling pertaining to the product.

C.2.3.2 The CB shall ensure that systems and facilities upon which an operator relies to produce and/or prepare each product included within its application is visited by the organic inspector to ensure that the standards are fully applied and correspond to the submitted production or preparation specifications.

C.2.3.3 The CB shall ensure that the inspection covers the entire agricultural production system being managed by the operator, even if only part of the operator's operations were targeted by the certification application.

C.2.3.4 The CB shall ensure that the land, premises and equipment not included in the certification application are identified and checked, and shall at a minimum include the following: crop areas or harvesting zones; harvest storage locations; preparation, processing and packaging sites; application dates for phytosanitary products.

C.2.3.5 The CB shall verify the accuracy of submitted documentation and its conformance to the requirements of the organic standard.

C.2.3.6 The CB shall verify that prohibited substances have not been and are not being applied to the operation.

C.2.3.7 The CB shall ensure that the VO conducts a review of record keeping to verify that the organic plan accurately reflects the operation and is in compliance with the Canadian Organic Standard. Records to be verified include records related to production (e.g. inventory, sales, purchases) and to management (e.g. accounting, complaints, etc.) as well as appropriate product packaging and labelling.

C.2.3.8 The CB shall conduct an initial inspection of each production unit, building, or site (including vehicles) where production or preparation of agricultural and food products are carried out.

C.2.3.9 The CB shall ensure that the VO witnesses the way the operator proceeds at a given point within the production cycle, thus implying that the inspection shall be carried out when grounds, premises, and activities subjected to compliance requirements may be observed.

C.2.3.10 The CB shall ensure that the inspection shall include non-organic units where there is reason to suspect undeclared split production of similar products, and in any situation revealing high risk of cross-contamination. Where agricultural producers carry out split production, inspections shall allow visual determination of what is being planted in all cultivated fields within the production unit.

C.2.3.11 The CB shall ensure that the VO identifies and investigates areas of risk (e.g. potential contamination from neighbouring farm, flooding).

C.2.3.12 The CB shall ensure that for producers, the VO obtains an estimate of the potential yield for the coming year, as well as an audit of the balance in the quantities produced and sold over the previous period, and including amounts still in inventory during this same period.

C.2.3.13 The CB shall ensure that for applicants performing operations related to food preparation (processing and/or packaging), the VO audits an audit of the input/output balance for acquired commodities, and for the corresponding commodities included in the products sold and on inventory.

C.2.3.14 The CB shall ensure that the VO reviews traceback audits applying to certain products taken from the supplier's inventory or from a commercial outlet where its products have been placed for sale.

C.2.3.15 The CB shall ensure that the VO verifies that changes in the standards and requirements of the CB have been effectively implemented by the operator.

C.2.3.16 The CB shall ensure that the VO verifies that previously imposed conditions have been fulfilled.

C.2.3.17 The CB shall ensure that when samples are taken by the VO, the VO shall provide the operator with a receipt for each sample.

C.2.3.18 The CB shall ensure that the VO conducts interviews with supervisory personnel.

C.2.3.19 The CB shall ensure that the VO conducts a closing meeting at the end of the visit, intended to inform the operator's management of observations made concerning the compliance with certification requirements, without any corrective action request from the VO.

C.2.4 Timing of On-Site Inspections

C.2.4.1 In cases of agricultural operations, the timing of on-site inspection shall take place during the production season. This period begins as soon as all operations subject to inspection (seeding, tapping, etc.) begin and ends with the packaging or placing in containers for storage of products to be certified.

C.2.4.2 In cases involving processing operations, on-site inspections may be carried out any time during the year. On the other hand, for separated production (i.e. when both certifiable and non-certifiable products are manufactured at the same facility), the inspection shall be carried out at time when the products that are targeted for certification are being processed.

C.2.5 Evaluation Report

C.2.5.1 The VO shall prepare the report of inspection results and findings and shall conclude the inspection with a closing meeting, which provides opportunity for the operator to confirm the accuracy of information collected during the inspection. There shall be a record of this review by the operator. The VO must also address the need for any additional information as well as any issues of concern.

C.2.5.2 The VO shall provide the CB with a report of findings as to the conformity with all certification requirements, and include the following data as a minimum:

  1. date, time and duration of inspection;
  2. names of interviewees;
  3. identification of land and premises visited on the production/handling site;
  4. types of documentation audits performed (in/out balance sheet, yields/sales, audit trails by batches, etc.).

C.2.5.3 The CB shall prepare final evaluation report following a reporting procedure that suits its needs but shall ensure that the requirements from ISO/IEC Guide 65 are met.

C.2.6 Non-Compliance Follow-Up

C.2.6.1 The CB shall give the applicant a reasonable length of time to address all non compliances and to become compliant.

C.2.6.2 The CB shall repeat only the necessary parts of the initial procedure if the applicant can show that remedial action has been taken to resolve all non compliances within a specified time limit. This means that it shall ensure, based on submitted documentation and if necessary, an on-site inspection, whether or not non-conformities were resolved.

C.2.6.3 The CB shall inform the applicant that at any point within the certification cycle, preceding the CB's decision, the applicant may request that the processing of its application be stopped. The applicant shall be informed that they are liable for the costs of services provided up to the time of withdrawal of its application. In such case, the CB shall not issue a decision regarding the products that were the subject of the certification request.

C.2.6.4 If a CB has reason to believe that an applicant for certification has wilfully made a false statement regarding its production system and operations related to the products included in the application, the CB may deny certification, without issuing a notification of non-compliance.

C.2.6.5 The CB shall issue a written notice of denial of certification to any applicant to whom it refuses certification, either because operations resulting in the products included in the application are still noncompliant with requirements or simply because the applicant did not respond to the notification of non-compliance. This notice shall state the reason(s) for denial and the applicant's right to:

  1. file an appeal of the denial;
  2. reapply for certification to any accredited CB, including the one who refuses certification.

C.2.7 Certification Decision

C.2.7.1 The decision to certify a product shall be taken if the CB determines that all procedures and activities contained in the production or preparation plan are in compliance with OPR requirements and that the applicant is able to conduct operations in accordance with this plan or after the corrections of minor non-compliances. This acceptance is valid until the results of the next annual evaluation are known and a new decision is made.

C.2.7.2 The CB shall issue documents to the applicant confirming the organic certification of the product. These documents shall include the following:

  1. the scope of the certification granted, including, as appropriate:
    1. the products certified, which must be identified by type or range of products including their specific name and if applicable, the one or more trademarks under which they are being marketed;
    2. the product standards or other normative documents concerning, under which each product or product type is certified;
    3. the applicable certification system (as defined by ISO Guide 67) with the type(s) of operations and subject of the evaluation by the CB, among the following:
      • crop production;
      • livestock production;
      • grain production;
      • maple syrup production;
      • specialized production (bee-keeping, etc);
      • food processing;
      • subsequent packaging (labelling modification following an operation of breaking down or regrouping on products already certified);
      • brokerage
  2. the date on which the certification was granted;
  3. the date by which the operator shall submit application for subsequent annual inspection;
  4. the location of all operations covered by this certification (town, province/state, country);
  5. in the case of product packaging and labelling certification, the date on which it expires which may not exceed 12 months.

C.2.7.3 The certification of a product, once issued, shall remain valid unless suspended or cancelled by the CB according to the requirements of the OPR or withdrawn by the operator.

C.2.8 Procedure for Continuation of Certification

C.2.8.1 The CB shall notify the applicant of any amendments to the regulations or the standards within two months after their publication.

C.2.8.2 The CB shall document the procedures to verify annually that the criteria for certification continue to be met by the operator.

C.2.8.3 The CB shall require that the operator apply annually for continued organic certification.

C.2.8.4 The CB shall proceed when the operator submits all information requested by the CB and pays annual certification fees.

C.2.8.5 The CB shall initiate suspension or cancellation in cases where the application is not submitted within the time prescribed in the OPR (Section 12 (1)).

C.2.8.6 The CB shall evaluate applications for continued certification to verify that all the requirements for certification are met resulting either in continuation of the certification or initiation of suspension and cancellation

C.2.8.7 The CB evaluation for continued certification shall include as a minimum:

  1. An on-site inspection to each location where each operator is operating, to verify compliance with the applicable requirements.
  2. If an inspection visit shall occur on a date beyond a period of twelve months following the inspection from the previous year, this postponement must not exceed six months, shall be justified and shall be documented.
  3. When the interval between two regular inspections has exceeded twelve months, the CB shall make sure that subsequent inspections restore the parity between the number of calendar years and the number of regular inspections over a given period.

C.2.8.8 The CB shall issue documents to the applicant confirming the organic certification of the product when the CB determines that the certified product continues to comply with the regulations.

C.2.9 Additional Inspections

C.2.9.1 The CB shall document a procedure covering the frequency of unannounced on-site inspections. At the beginning of the year the CB shall plan unannounced visits, representing 3% of primary producers and 5% of other operators to which it grants certificates for products under the Canada Organic Regime.

C.2.9.2 The CB shall comply with any requests from the Canada Organic Office or the CVB that additional inspections be conducted by the CB when the compliance of the operation is in doubt or for other valid reasons.

C.2.10 Suspension and Cancellation

2.10.1 The CB shall suspend an organic certification as per Section 20 from the Regulations as amended from time to time.

C.3 Sale or Distribution of Certified Product

C.3.1 The CB shall ensure that the operator does not put up for sale any product for which it has requested certification; and bearing the word organic or its derivatives and marked according to the CB's requirements, for as long as it has not been informed of the decision made by the CB stating that the products are certified.

C.4 Appeal, Complaint and Dispute Procedures of CB

C.4.1 The CB shall document procedures to ensure that it deals with the appeals, complaints and disputes by an applicant or other party pertaining to certification

C.4.2 The CB documented procedures shall deal with, as a minimum:

  1. appeals related to certification decisions;
  2. complaints or objections from operators regarding the CB's program application;
  3. complaints or objections from outside persons or organizations about the CB's operation.

C.5 Issues Regarding Implementation of the Standard

C.5.1 The CB shall allow a period of up to 12 months after the publication date of an amendment to CAN/CGSB-32.310 and CAN/CGSB-32.311 for applicant to come into compliance with any changes to the requirements.

C.5.2 If at any point during certification activities, interpretation of an applicable standard is required, it can be sought from the Standards Interpretation Committee (SIC). Refer to Part G for details about this committee and on how to request an interpretation.

C.5.3 It is likely that the need for interpretation requests to the SIC will occur during a certification cycle of an operator by a CB. In such cases, once the interpretation request is submitted, the issue that is the subject of the request will be set aside by the CB (e.g. the nonconformity will be placed on hold) until the response from the SIC is returned.

C.5.4 In these cases, between the time when the interpretation request to the SIC is submitted and the response from the committee returned, any certification work affected by the interpretation shall proceed as normal, up to and including the issuance of certification documents.

C.5.5 When the response from the SIC is received, the outstanding issue shall be revisited and appropriate actions taken by the CB or the operator or both as required.

C.5.6 If changes are required by the operator to comply with the interpretation of the SIC, the CB shall not suspend or withdrawal any certification it has issued that is affected by this interpretation as long as the operator has made the required changes in a time frame that is no less than the time permitted for any other non-conformance issued by the CB.

C.6 Use of Licenses, Certificates and Marks of Conformity

C.6.1 The CB shall have a signed license agreement with each operator using the certification mark of the CB for products which it has certified.

C.6.2 The CB shall ensure that all certified products are labelled in accordance with the OPR.

C.6.3 The CB shall withdraw the license if the operator:

  1. ceases doing business with the CB; or
  2. ceases to supply, as affiliated operator, a customer whose products are certified by the CB; or
  3. ceases, if it sells private label products without itself owning a certificate, to purchase from suppliers whose products are certified by the CB; or
  4. cannot demonstrate that it is able to comply with the prescribed standards for operations included in its certification application.

C.6.4 The CB shall have procedures to monitor products using its certification mark and being sold on the market, to detect any improper or fraudulent use of their mark and mandatory labelling (Section 25 of the OPR).

C.6.5 The CB shall have written rules authorizing the use of its mark (including the recognition of product labels on which it shall be displayed) and is responsible for delivering the organic certificates. The CB shall have written procedures for dealing with abusive use, false statements regarding a product's certification or the incorrect use of its certification marks. The CB shall have procedures ensuring that its operators do not allow its certification mark be used in any way likely to lead to confusion among consumers.

C.7 Obligations of the CB Relative to Certifications

C.7.1 The CB shall not issue a certificate for any product unless all previously certified products or ingredients have been certified under the OPR requirements.

C.7.2 The CB shall require that the party owning the product at the point of transport be responsible, and keep records, for maintaining the organic integrity in the transport process, unless transport operations are certified in their own capacity.

C.7.3 When a subjective judgment is required to determine compliance, the CB shall document explanatory information, assuring consistent and uniform application of the requirements and certification decisions.

C.7.4 The CB shall ensure that when it identifies and assigns responsibilities and tasks to members of its staff, impartiality is not in jeopardy.

C.7.5 The CB shall identify the management (committee, group or person) which have overall responsibility for undertaking monitoring, inspection and certification activities as defined within the accreditation criteria, including execution of inspection, controls, evaluation and certification.

C.7.6 The CB shall have a signed agreement with each operator that specifies the rights and responsibilities relevant to its certification activities.

C.7.7 The CB shall include provisions to cover liabilities in situations where there is a significant risk of being sued.

C.7.8 The CB shall document the minimal qualifications required for VO. The CB shall ensure relevant professional training or experience in compliance with the CB' Quality Management System requirements including training with respect to the Canada Organic Regime.

C.7.9 The CB shall have a signed agreement with the VO to refuse any work that would create a conflict-of-interest situation with the enterprise that is applying for certification, either because of a family link, or because of a business relationship with the applicant during the twelve months preceding its application to the CB.

C.7.10 The CB shall document its rules for inspection.

C.7.11 The CB shall record its VO selection and VO performance appraisal.

C.7.12 The CB shall document the grounds on which an applicant might refuse the choice of VO and shall inform the operator of these grounds, prior to, or along with, the name of the VO being provided to the operator.

C.7.13 The CB shall document the terms defining the verification mandate.

C.7.14 The CB shall document frequency and estimated duration of verification, taking into account the intensity of the production system, the production type, the company's size, the results of the previous verification, complaints received, parallel production.

C.7.15 The CCB shall document the minimum requirements for any audit trail, in relation to traceability.

C.7.16 The CB shall document its sampling requirements (when applicable).

C.7.17 The CB shall document its deadlines for presentation of the verification report to the CB.

C.8 Records Control by the CB and Operator

C.8.1 The CB shall document procedures that ensure it maintains a record system that complies with existing regulations.

C.8.2 The CB shall ensure that its records are to be kept for a minimum of five years. This requirement shall also be documented by the CB.

C.8.3 The CB shall ensure that the operator maintain records and relevant supporting documents concerning the inputs, production, preparation and handling of crops, livestock and organic products that are or are intended to be sold, labelled or otherwise represented as organic in accordance with the CAN/CGSB-32.310.

C.9 CB Records

C.9.1 The CB shall record all data listed below shall provide it to the CVB and COO annually by the end of the calendar year for each operator granted certification. For those elements of this information provided via the Internet, it is acceptable to provide the URL to this information instead. For those elements of this information not provided via the Internet, that information shall still be provided annually by the CB.

  1. Legal (corporate) name of operator.
  2. Full address of the of operator's head office including phone numbers and fax numbers.
  3. Type of operation (primary, processing or exporter).
  4. Generic names of the products certified.
  5. One example of a package using the certification marking (an electronic copy is acceptable).

C.9.2 The CB shall maintain records of all major changes that took place during the previous year and that have affected corporate structure and directors, the administrative structure, the main managers of the organization and members of the committees.

C.9.3 The CB shall maintain records of all modifications made to policies, internal procedures and regulations governing the organization and its certification system.

C.9.4 The CB shall maintain records of the certificates newly issued, renewed, suspended and withdrawn listed by operator category under the COR.

Next Page: Part D - Use Of The Canada Organic Logo | Previous Page: Part B - Accreditation of Certification Bodies

Date Modified: 2010-10-25

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